Page 28 - The TEFRA Partnership Audit Rules Repeal:

Section 6231: Commencement and Conclusion of Partnership Audit
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The IRS is required to mail the following notices to the partnership and the partnership representative:
− Notice of administrative proceeding;
− Notice of proposed adjustment resulting from such proceeding (NOPA); and − Notice of final partnership adjustment (FPA).
FPA shall not be mailed earlier than 270 days after the NOPA is mailed.
Notices are sufficient if mailed to last known address of the partnership representative or the partnership (even if the partnership has terminated its existence).
If partnership challenges the FPA in a judicial proceeding, the IRS is prohibited from issuing another FPA for the taxable year, absent the showing of fraud, malfeasance, or misrepresentation of material fact.
The IRS may, with the consent of the partnership, rescind any notice of a partnership adjustment.
©2016 Sutherland Asbill & Brennan LLP
Coming changes to IRS Audits of partnerships 19